Pedido de Vista Regimental adia o julgamento de processo sobre Imposto sobre a Renda de Pessoa Jurídica (IRPJ) e Lucros Auferidos no Exterior – Conversão para Reais
Autor | Alexandre Pontieri |
Cargo | Membro da Comissão de Direito Criminal da OAB-SP |
Pedido de Vista Regimental adia o julgamento de processo sobre Imposto sobre a Renda de Pessoa Jurídica (IRPJ) e Lucros Auferidos no Exterior – Conversão para Reais.
Um pedido de vista regimental feita pelo Conselheiro Valmar Fonseca de Menezes adiou o julgamento do Processo nº 16327.001170/2006-62, que trata de questão de grande importância para o direito tributário internacional sobre a seguinte matéria:
IMPOSTO SOBRE A RENDA DE PESSOA JURÍDICA - IRPJ
Exercício: 2003
LUCROS AUFERIDOS NO EXTERIOR. CONVERSÃO PARA REAIS. Os lucros auferidos no exterior por intermédio de filiais, sucursais, controladas ou coligadas serão convertidos em Reais pela taxa de câmbio, para venda, do dia das demonstrações financeiras em que tenham sido apurados os correspondentes lucros.
CSLL. LUCROS AUFERIDOS NO EXTERIOR. Tratando-se de lucros auferidos por controladas, no exterior, de pessoa jurídica domiciliada no país, a Lei n°9.532, de 1997, não atuou modificando a data da ocorrência do fato gerador, mas, tão-somente, deslocou o momento em que esses lucros deveriam ser oferecidos à tributação, homenageando, no caso, os princípios da uniformidade e da realização. Nessa linha, a tributação da CSLL em bases universais só se aplica aos lucros auferidos a partir de 10 de outubro de 1999.
LUCROS AUFERIDOS NO EXTERIOR. EQUIVALÊNCIA PATRIMONAL. VARIAÇÃO CAMBIAL. Nos termos de manifestação advinda do Ministério da Fazenda no âmbito do veto parcial ao Projeto de Lei de Conversão n° 30, de 2003 (art...
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